Howlett Ex Rel. Howlett v. Rose’s Empirical Analysis
1990
Citation profile
199 federal appellate · 85 district · 694 state decisions
How this case has been cited
Cited by 1,385 later decisions (25 by the Supreme Court) — most recently December 2025 · most notably Exxon Mobil Corp. v. Saudi Basic Industries Corp. (2005), John Aldens v. Maine (1999)
199 federal appellate · 85 district · 694 state decisions — followed in 45 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 28 U.S.C. § 1257 · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act)) · 42 U.S.C. § 1988
Relies on Monell v. Department of Social Services of City of New York · Scheuer v. Rhodes · Mt. Healthy City School District Board of Education v. Doyle · City of Canton v. Harris · Will v. Michigan Department of State Police
Cited together with Will v. Michigan Department of State Police · Monell v. Department of Social Services of City of New York · Harlow v. Fitzgerald · Martinez v. California · Felder v. Casey
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 1,385 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The elements of, and the defenses to, a federal cause of action are defined by federal law.”
25 later decisions quote this exact passage · from the dissent“[T]he Constitution and laws passed pursuant to it are as much laws in the State as laws passed by the state legislature. The Supremacy Clause makes those laws “the supreme Law of the Land,” and charges state courts with a coordinate responsibility to enforce that law according to their regular modes of procedure.”
21 later decisions quote this exact passage · from the majority“Conduct by persons acting under color of state law which is wrongful under 42 U.S.C. § 1983 or § 1985(3) cannot be immunized by state law. A construction of the federal statute which permitted a state immunity defense to have controlling effect would transmute a basic guarantee into an illusory promise; and the supremacy clause of the Constitution insures that the proper construction may be enforced.”
15 later decisions quote this exact passage · from the dissent
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.